PRIVACY POLICY

Respecting the provisions of current legislation, TOT DESTINS (hereinafter, also Website) undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected. Laws incorporated in this privacy policy This privacy policy is adapted to current Spanish and European regulations regarding the protection of personal data on the Internet. Specifically, it respects the following rules: Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons with regard to the processing of personal data and the free circulation of these data (RGPD). Organic Law 15/1999, of December 13, on the Protection of Personal Data (LOPD). Royal Decree 1720/2007, of December 21, which approves the Regulations for the development of Organic Law 15/1999, of December 13, on the Protection of Personal Data (RDLOPD). Law 34/2002, of July 11, on Services of the Information Society and Electronic Commerce (LSSI-CE). Identity of the person responsible for the processing of personal data The person responsible for processing the personal data collected in TOT DESTINS is: Lluís Soler, with NIF: XXXXXXXXX (hereinafter, Data Controller). His contact details are as follows: Address: Carrer Sant Domènech, 2, Cerdanyola del Vallès, 08290 Contact telephone number: 935 94 86 48 Contact email: lluis.soler@totdestins.com 

Registration of Personal Data

The personal data collected by TOT DESTINS, through the forms extended on its pages, will be entered into an automated file under the responsibility of the Data Controller, and duly declared and registered in the General Registry of the Data Protection Agency that can be consulted on the website of the Spanish Agency for Data Protection (http://www.agpd.es), in order to be able to facilitate, speed up and full fill the commitments established between TOT DESTINS and the User or the maintenance of the relationship that is established in the forms that it fills out, or to attend to a request or query from it. Principles applicable to the processing of personal data The processing of the User’s personal data will be subject to the following principles set out in article 5 of the RGPD:

Principle of legality, loyalty and transparency: the User’s consent will be required at all times prior to completely transparent information on the purposes for which the personal data is collected. Purpose limitation principle: personal data will be collected for specific, explicit and legitimate purposes.

Principle of data minimisation: the personal data collected will only be strictly necessary in relation to the purposes for which they are processed. Accuracy principle: personal data must be exact and always updated.

Principle of limitation of the term of conservation: the personal data will only be maintained in a way that allows the identification of the User for the time necessary for the purposes of its treatment. Principle of integrity and confidentiality: personal data will be treated in a way that guarantees its security and confidentiality.

Principle of proactive responsibility: the Data Controller will be responsible for ensuring that the above principles are met. Categories of personal data The categories of data that are treated in TOT DESTINS are only identifying data. In no case are special categories of personal data processed within the meaning of Article 9 of the GDPR. Legal basis for the processing of personal data The legal basis for the processing of personal data is consent. TOT DESTINS undertakes to obtain the express and verifiable consent of the User for the processing of their personal data for one or more specific purposes.

The User shall have the right to withdraw his consent at any time. It will be as easy to withdraw consent as it is to give it. As a general rule, the withdrawal of consent will not condition the use of the Website. On occasions in which the User must or can provide their data through forms to make inquiries, request information or for reasons related to the content of the Website, they will be informed if the completion of any of them is mandatory. because they are essential for the proper development of the operation performed.

Purposes of the treatment to which the personal data is destined The personal data is collected and managed by Lluís Soler in order to be able to facilitate, speed up and full fill the commitments established between the Website and the User or the maintenance of the relationship established in the forms that the latter fills out or to attend to a request. request or inquiry. Likewise, the data may be used for a commercial personalisation, operational and statistical purpose, and activities of the corporate purpose of Lluís Soler, as well as for the extraction, storage of data and marketing studies to adapt the Content offered to the User, as well as how to improve the quality, operation and navigation of the Website. At the time the personal data is obtained, the User will be informed about the specific purpose or purposes of the treatment to which the personal data will be used; that is, the use or uses that will be given to the information collected. Personal data retention periods Personal data will only be retained for the minimum time necessary for the purposes of its treatment and, in any case, only for the following period: 5 years, or until the User requests its deletion. At the time the personal data is obtained, the User will be informed about the period during which the personal data will be kept or, when this is not possible, the criteria used to determine this period. Recipients of personal data The User’s personal data will be shared with the following recipients or categories of recipients: Google Analytics with registered office in California 08190 USA In the event that the Data Controller intends to transfer personal data to a third country or international organisation, at the time the personal data is obtained, the User will be informed about the third country or international organisation to which the transfer is held. intention to transfer the data, as well as the existence or absence of an adequacy decision by the Commission. Personal data of minors Respecting the provisions of articles 8 of the RGPD and 13 of the RDLOPD, only those over 14 years of age may grant their consent for the processing of their personal data in a lawful manner by TOT DESTINS.

If it is a minor under 14 years of age, the consent of the parents or guardians will be necessary for the treatment, and this will only be considered lawful to the extent that they have authorised it. Secrecy and security of personal data TOT DESTINS undertakes to adopt the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in such a way as to guarantee the security of personal data and avoid destruction, loss or accidental alteration or illicit transmission of personal data, stored or otherwise processed, or unauthorised communication or access to such data. However, because TOT DESTINS cannot guarantee the impregnability of the Internet or the total absence of hackers or others who fraudulently access personal data, the Data Controller undertakes to notify the User without undue delay when a violation occurs. of the security of personal data that is likely to entail a high risk for the rights and freedoms of natural persons.

Following the provisions of article 4 of the RGPD, a breach of the security of personal data is understood to be any breach of security that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or unauthorised communication or access to such data. Personal data will be treated as confidential by the Data Controller, who undertakes to report and guarantee through a legal or contractual obligation that said confidentiality is respected by its employees, associates, and any person to whom it makes the information accessible. information. Rights derived from the processing of personal data The User has over TOT DESTINS and may, therefore, exercise the following rights recognised in the RGPD against the Data Controller: Right of access: It is the right of the User to obtain confirmation of whether or not TOT DESTINS is treating their personal data and, if so, to obtain information about their specific personal data and the treatment that TOT DESTINS has carried out or carries out, as well such as, among others, the information available on the origin of said data and the recipients of the communications made or planned for them.

Right of rectification: It is the right of the User to modify their personal data that turns out to be inaccurate or, taking into account the purposes of the treatment, incomplete. Right of deletion («the right to be forgotten»): It is the right of the User, provided that the current legislation does not establish otherwise, to obtain the deletion of their personal data when these are no longer necessary for the purposes for which they were collected or processed; the User has withdrawn his consent to the treatment and this does not have another legal basis; the User opposes the treatment and there is no other legitimate reason to continue with it; the personal data has been unlawfully processed; the personal data must be deleted in compliance with a legal obligation; or the personal data has been obtained as a result of a direct offer of information society services to a child under 14 years of age. In addition to deleting the data, the Data Controller, taking into account the available technology and the cost of its application, must take reasonable measures to inform those responsible for processing the personal data of the interested party’s request to delete any link to those personal data.

Right to limitation of treatment: It is the User’s right to limit the treatment of their personal data. The User has the right to obtain the limitation of the treatment when he contests the accuracy of his personal data; the processing is unlawful; the Data Controller no longer needs the personal data, but the User needs it to make claims; and when the User has opposed the treatment.

Right to data portability: In the event that the treatment is carried out by automated means, the User will have the right to receive their personal data from the Data Controller in a structured format, of common use and mechanical reading, and to transmit them to another person in charge. of the treatment. Whenever technically possible, the Data Controller will transmit the data directly to that other controller.

Right of opposition: It is the right of the User not to carry out the processing of their personal data or to cease the processing thereof by TOT DESTINS. Right not to be the subject of a decision based solely on automated processing, including profiling: It is the User’s right not to be the subject of an individualised decision based solely on the automated processing of their personal data, including the profiling, existing unless current legislation establishes otherwise. Thus, the User may exercise their rights by written communication addressed to the Data Controller with the reference “RGPD-www.totdestins.com”, specifying: Name, surnames of the User and copy of the DNI. In cases where representation is admitted, identification by the same means of the person representing the User will also be necessary, as well as the document accrediting the representation. The photocopy of the DNI may be replaced by any other legally valid means that proves identity. Request with the specific reasons for the request or information to which you want to access. Address for notification purposes. Date and signature of the applicant. Any document that accredits the request made.

This application and any other attached document may be sent to the following address and/or email: Postal address: Carrer Sant Domènech, 2, Cerdanyola del Vallès, 08290 Email: lluis.soler@totdestins.com Links to third party websites The Website may include hyperlinks or links that allow access to web pages of third parties other than TOT DESTINS, and therefore are not operated by TOT DESTINS. The owners of these websites will have their own data protection policies, being themselves, in each case, responsible for their own files and their own privacy practices. Claims before the control authority In the event that the User considers that there is a problem or infringement of current regulations in the way in which their personal data is being processed, they will have the right to effective judicial protection and to file a claim with a control authority, in particular, in the State in which you have your habitual residence, place of work or place of the alleged infringement. In the case of Spain, the control authority is the Spanish Data Protection Agency (http://www.agpd.es).

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Responsible: Tot Destins
Purpose: Collection of personal data to be able to attend to your request
Legitimation: Consent of the interested party
Recipients: No data will be transferred to third parties, except legal obligation
Rights: Access, rectify or delete the data, as well as other rights, as explained in the additional information.

Address

C/ Sant Doménec, 2 B.
08290 Cerdanyola del Vallés

Phone

93 594 86 48

Information

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